The U.S. Department of Homeland Security (DHS) recently promulgated an interim final rule that imposes comprehensive federal security regulations for high-risk chemical facilities; the Chemical Facilities Anti-Terrorism Standards require Penn to report possession of over 300 Chemicals of Interest (COI) if any of the listed chemicals are possessed at or above a specific regulatory limit called the Screening Threshold Quantity (STQ). Penalties of up to $25,000/day are possible for violations of the rule. Because of the very short timeline for compliance with the DHS mandate, February 29, 2008 is the deadline for reporting possession of any DHS listed chemicals to Environmental Health and Radiation Safety (EHRS). The timely cooperation of those who use or store chemicals is vital to achieving compliance with this rule.
In order to comply with the rule, a careful review of chemicals used or stored throughout the university must be conducted, except for School of Medicine and School of Veterinary Medicine buildings in Philadelphia. Faculty and other managers are responsible for inventorying their labs/areas and reporting, to Environmental Health and Radiation Safety (EHRS), the possession of DHS listed COIs in any room or area for which they are responsible. To assure complete inventories, rooms that do not have COIs must also be reported. A two phase process was developed to gather and aggregate the information.
EHRS provides a list of COIs on its website for Principal Investigators and others to use in conducting the inventory of COIs in each space, lab or room, where chemicals are used or stored.
Use the CFATS Inventory Form to inventory rooms prior to completing Phase II. Please keep your copies of the inventory for reference if EHRS has questions.
CFATS Inventory Form: List of Chemicals of Interest (COI) [PDF]
(Use one form for each building in which you use or store chemicals.)
EHRS developed a website for entering COI information for aggregation. This website must be used to report quantities, by building and room(s), of any amount of COI’s. EHRS will aggregate the data and submit any required reports to DHS.
Online submission website [PennKey required]